Plaintiff Tasha Sherman-Harris-Golson, sued Forest Park Municipal Authority, the Town of Forest Park, and several of its employees, including Tyara Nash-Richmond, Thomas Gipson, and Joseph Milton, raising various Title VII and Section 1983 Claims. The defendants moved for summary judgment.
Plaintiff’s Factual Allegations:
Golson, a former employee of Forest Park, commenced her role as a reserve police officer in September 2018 and was terminated in November 2019. In May 2021, she sued Forest Park and several of its employees, alleging various employment claims under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1981, and 42 U.S.C. § 1983. Her claims include gender discrimination, a hostile work environment, and retaliation. She details incidents like derogatory remarks during a class, removal of investigative duties, non-compliance with the uniform policy, and interactions with Milton, alleging these actions constituted gender-based discrimination and a hostile work environment.
Court’s Analysis and Rulings:
Section 1983 Equal Protection Claim Against Milton: The court addressed Golson’s § 1983 equal protection claim against Milton. It focused on whether the second alleged sexual assault, claimed to have occurred within the statute of limitations, was time-barred. The court found that Golson provided enough evidence to raise a genuine issue of material fact about the timing of this second assault, denying Milton’s motion for summary judgment on this claim.
Title VII Claims Against Forest Park:
Gender Discrimination – Disparate Treatment: The court analyzed Golson’s gender discrimination claim against Forest Park. While it found that Golson failed to establish a prima facie case for her disciplinary suspension and termination, it concluded that there was enough evidence to suggest possible gender discrimination in her placement on paid administrative leave. Thus, the court denied summary judgment for Forest Park on this aspect of the gender discrimination claim.
Hostile Work Environment – Sexual Harassment: Regarding the hostile work environment claim, the court determined that Golson had provided sufficient evidence to suggest that Milton’s conduct was severe enough to create an abusive working environment. Forest Park’s potential liability for Milton’s conduct was also considered, with the court finding a genuine issue of material fact as to whether Milton was a supervisor under Title VII, influencing Forest Park’s liability. The court thus did not grant summary judgment to Forest Park on this claim.
Retaliation Claim: Concerning the retaliation claim, the court noted that while the termination occurred over three months after Golson reported the alleged sexual assaults, there was other evidence suggesting a causal connection, such as the timing of information provided about Golson’s work performance, gathered after she reported the assaults. Therefore, the court found a genuine issue of material fact about the pretext of Forest Park’s reasons for Golson’s termination, denying summary judgment on the retaliation claim.
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